CONTINGENCY AND SPILL RESPONSE PLAN Prepared for: WESTERRA ENTERPRISES INC. #109 32885 Mission Way Mission, BC V2V 6E4 Prepared by: KEYSTONE ENVIRONMENTAL LTD. Suite 320 4400 Dominion Street Burnaby, BC V5G 4G3 Telephone: 604-430-0671 Facsimile: 604-430-0672 www.keystoneenvironmental.ca Project No. 12943 March 2016
PREFACE This contingency and spill response plan is designed to conform to the Environmental Management Act, BC Contaminated Sites Regulation, BC Spill Reporting Regulation, and Canada Shipping Act: National Spill Response Protocol. The barge loading facility receives graded IL soil. The transfer station facilitates delivery of contaminated soils to soil treatment facilities in the Lower Mainland and Fraser Valley. Trucks bring soils to the facility where they are temporarily stored before being transferred to a barge and transported to an approved treatment facility. Westerra Enterprises Inc. (Westerra) minimizes any possible impact of its operations by utilizing best available control technologies and operating procedures. i Project 12943 / March 2015
TABLE OF CONTENTS Page EMERGENCY ACTION PLAN... 1 1.1 Shut Down Procedures... 1 1.2 Initial Response... 1 1.3 Spill Report Form... 2 1.4 Emergency Notification Procedures... 2 1.4.1 Responding to a Fire... 3 1.4.2 Marine Spill... 3 1.4.3 Contact List... 4 1.5 Command Structure Strategy... 4 1.6 Timing Standards for Emergency Response Strategy... 4 1.7 Health and Safety Requirements... 5 CONTINGENCY PLAN MANAGEMENT... 6 2.1 Authority and Commitment... 6 HAZARD ANALYSIS... 7 3.1 Soil Spill... 7 3.2 Oil or Fuel Spill... 7 SENSITIVITY ANALYSIS... 8 4.1 Biological Sensitivities... 8 4.2 Socio-Economic Sensitivities... 8 SPILL RESPONSE ORGANIZATION AND LOGISTICS... 9 5.1 Command System... 9 5.2 Communications... 9 SPILL REPORTING AND LIAISON... 10 6.1 Spill Reporting Contact List... 10 6.2 Spill Reporting... 10 6.3 Public Information... 11 CONTAINMENT AND CONTROL... 12 7.1 Spill Kits... 12 7.2 Equipment Capabilities and Limitations... 13 iii Project 12943 / March 2015
TABLE OF CONTENTS (CONT'D) Page 7.3 Equipment Storage and Maintenance... 13 7.4 Safety of the Clean-up Crew... 13 ASSESSMENT AND SURVEILLANCE... 15 8.1 Monitoring Procedures... 15 8.2 Documentation Procedures... 15 TRAINING... 16 9.1 Objectives... 16 9.2 Training of Personnel... 16 SPILL CONTROL AND CLEAN-UP PROCEDURES... 17 10.1 Restoration of Spill Site... 17 LIST OF APPENDICES Appendix A Spill Report and Notification Form iv Project 12943 / March 2015
EMERGENCY ACTION PLAN The objective of the Emergency Action Plan is to delineate the sequence of initial notification and response actions. It is designed to promote a rational and effective emergency response and preserve a chronological record of actions taken. The spill section of this plan should be consulted for all spills that may occur; from large spills that need outside assistance to control, to very minor operational spills that occur from time to time, which are controlled by on-site staff. Westerra site staff is responsible for the control and ultimate clean-up of spills on site. While all spills must be reported internally following details in Section 6, emergency notification shall only be conducted for large spills, or potentially health or life threatening situations. Spill containment will be the primary emergency response activity, followed by shut down procedures and finally clean up procedures. Westerra only accepts soils that are classified to be Industrial Land Use (IL) standard or below. No liquid wastes are permitted to be received at the facility. Soils arriving at the transfer facility that are not approved of or arrive without the prescribed paperwork will not be accepted at the facility and will be turned away. 1.1 Shut Down Procedures Contaminated soils will be the predominant waste types handled. Spills of contaminated soils do not represent a human health hazard. Containment and clean-up response can be done without undue risks of contaminating surrounding areas. Decontamination for these types of wastes is relatively simple. Liquid spills in the form of oil, waste oil, hydraulic fluid, oily water/bilge, gasoline, diesel, solvents, antifreeze, grease, etc. may occur on site. The severity of the spill and the decontamination procedure depends on volume, proximity to the waterway, drains, or other pathways to the receiving environment. 1.2 Initial Response On noticing a potential spill, spill, or equipment malfunction, the observer shall immediately stop work and shut down equipment. They will then alert the other crew member(s) on site. If the site is small, with all sections within shouting and seeing distance, this alerting can be accomplished easily. On large sites, other crew members can be alerted with on-site air horns. The on-site safety officer, using the approved Health and Safety manual procedures, shall then assess the potential safety hazard of the situation. If the safety risk is moderate to high, the on-site safety officer shall assign the staff to initiate wider shut down procedures, while the safety officer completes a Spill Report Form (Section 1.3) and initiates emergency notification procedures (Section 1.4). All parties are to remain at the scene until the required information is gathered. Initial response to spills will be as follows: 1 Project 12943 / March 2015
Stop work, shut down equipment involved. Assess safety risks in the spill area. Notify the Site Safety Officer. Stop the flow of the hazardous material if safe to do so. Secure and isolate spill area. Assess the situation (identify product, equipment involved, affected area, spill status, time of spill). Begin containing and recovering the spill with on-site emergency spill equipment if safe to do so. Complete the spill report form, as described below. 1.3 Spill Report Form A standard Spill Report Form shall be completed as soon as possible after detecting a spill. The information in the report will be used during notification (Section 1.3) and form an accurate record of events and decisions throughout the spill. Consequently, spill report forms shall be completed hourly for the first 24 hours after a spill, every 4 hours until 72 hours have passed or until the spill clean-up objectives are achieved. A personnel and equipment inventory should be kept to track workers and equipment used in the response. The inventory should include: Location used; Personnel responsible; Time used (logged in/logged out); and Performance or effectiveness. 1.4 Emergency Notification Procedures Emergency notification should proceed if a large spill occurs, if a spill occurs that poses potentially hazardous risks, or if there is a life or health-threatening situation (Section 6). The Emergency Coordination Centre (ECC) shall be notified and will respond at their discretion. If emergency notification is indicated by the size or potential hazards of the spill, the on-site safety officer shall initiate a call fan out within five minutes of detecting a spill, unless there is a lifethreatening situation. The caller shall be prepared to give a concise and thorough recounting of the information received in the spill report. The following information shall be provided in the First Call: Time of spill incident/time reported Location of spill Size of spill 2 Project 12943 / March 2015
Type of substance spilled Circumstances of spill (truck dumping, tank leak, etc.) Present status of spill (stopped, contained, etc.) Response action being taken Weather conditions 1.4.1 Responding to a Fire In response to a fire, the first call shall be made to the Local Fire Department. For all personnel employed at the site, they will undergo initial training dealing with emergency response reporting, as well as fire training and personnel safety procedures. Training will be ongoing at 4 week intervals and will be part of the overall work program. Safety meetings fall in conjunction with the training schedule. Westerra Enterprises Inc. will work closely with the local fire department and assist in any way possible. Employees will be trained in the basics of fire prevention, safety and firefighting procedures. On receipt of their calls, the Fire Department and ECC will initiate their own fan-outs to all relevant agencies and response team members. 1.4.2 Marine Spill The 24-hour marine spill number is the same as the Emergency Coordination Centre (ECC) listed in section 1.4.3. The marine spill number shall be the first contact and other agencies, such as the Canadian Coast Guard, may be contacted subsequently depending on the size and nature of the spill. The National Spill Response specifies that the Canadian Coast Guard is responsible for all spill response and recovery in Canada. Port Metro Vancouver has jurisdiction over the Fraser River, and may be called upon by the Coast Guard to assist with initial inspection of a spill. The Coast Guard contracts spill clean up to Western Canada Marine Response Corporation on the west coast. If the spill is determined to be an incident, the ECC will determine the next course of action. 3 Project 12943 / March 2015
1.4.3 Contact List Contact information is: Authority Contact Phone number Emergency Services (police, fire, ambulance) Emergency Dispatch 911 Emergency Coordination Centre Duty Officer 1-800-663-3456 Canadian Coast Guard 604-775-8881 Port Metro Vancouver Operations Centre 24/7 Operations Centre/ Port emergencies 604-665-9086 Westerra Enterprises Inc. Myles Hargrove 604-825-2010 Western Canada Marine Response Corporation 24-hour spill emergency line 604-294-9116 or 1-855-294-9116 Royal Columbian Hospital 604-520-4253 Non-emergency local police Non-emergency line 604-525-5411 Non-emergency local fire Non-emergency line 604-519-1004 Tervita (3rd party spill response) 24 hr Emergency Response 1-800-327-7455 Terrapure Environmental (3rd party spill response) 604-596-6559 1.5 Command Structure Strategy Leadership of a spill response will depend on the size of the spill. All spills, regardless of size, must be reported. If the spill is too small to require notification of government authorities, the onsite safety officer will notify BC Ministry of Environment (MoE) before conducting a safe and effective response and clean-up program. The on-site safety officer shall call other Westerra staff for assistance as required. If the Emergency Coordination Centre (ECC) has been called and additional personnel and equipment are required to manage the spill or incident, ECC will then establish a command structure fitting to the type and size of spill, whether there is a fire or a fire hazard and whether medical attention is required. 1.6 Timing Standards for Emergency Response Strategy After the first call has been made, the chief operator shall first ensure that immediate health and safety concerns are addressed and stable. The next step is to activate the communications procedures followed by mobilizing personnel and cleaning up equipment. A basic time schedule for the early response procedures should be as follows: Assessment of fire or health hazards within 3 minutes; Evacuation of area other than employees and emergency response personnel; Complete stoppage of all work related duties & operations within 6 minutes; Complete spill report form within 10 minutes; Execution of first stages of communication procedures within 15 minutes; 4 Project 12943 / March 2015
Activation of health and safety personnel for any medical emergency within 15 minutes; Prepare for arrival of outside spill response teams within 20 minutes; and Initiate mobilization for spill containment and clean-up activity within 20 minutes. 1.7 Health and Safety Requirements A spill response must strictly follow health and safety requirements outlined in Westerra s Health and Safety Plan (issued under separate cover). Briefly, these requirements address: Medical clearance and monitoring of all project personnel; A safety orientation meeting for all field personnel; A designated work zone around the site where all personnel are required to wear protective clothing, if required; Respirators are to be worn at the discretion of the Health and Safety officer; Two workers shall be in sight of each other at all times while on site; Decontamination procedures for any equipment and personnel must be followed prior to departure from the site if required; and Activities such as smoking and eating are prohibited on the site. 5 Project 12943 / March 2015
CONTINGENCY PLAN MANAGEMENT 2.1 Authority and Commitment Westerra is committed to conducting a thorough clean-up of any spills that occur on the job site and to cover any costs that may arise from an accidental spill. The personnel on site will be trained to respond to spills and fires to minimize potential liabilities. The entire offloading operation will be manned from the time the trucks arrive onsite to the time the barges are unloaded or loaded. Prior to the trucks arriving on the site, personnel will ensure all parts of the system (including emergency response systems) are functioning as intended. Prior to barge loading, personnel will confirm the barges are empty of debris, in good condition, and are properly closed. For barge unloading, a review of the barge will be completed following unloading. As part of the barging contract, Westerra will require contractors to submit maintenance and training records. 6 Project 12943 / March 2015
HAZARD ANALYSIS 3.1 Soil Spill Spillage of contaminated soils from trucks or handling equipment is the predominant potential source of spills. All equipment handling soil will be restricted in their movement around the work site. Trucks delivering soils will be allowed travel onto the site for unloading purposes. They will then travel directly to the final destination for disposal of the soil. Trucks working on site will be loaded with soil from the storage area and deliver the soil to the barges at the waterfront. Front-end loaders handling soils will have a one piece bucket to avoid leaks. Loader operators will be instructed to limit the size of each load to avoid spills. Equipment handling contaminated soils will be washed and decontaminated before leaving the work site. Front-end loaders will be decontaminated before handling other soils. In the event of a spill to the marine environment, the following mitigation measures will be implemented. Operations will stop and the site manager and the Port will be informed of the spill Personnel will make an estimate of the volume released and, in consultation with a qualified dredging professional, will determine if the material can be effectively recovered. This will depend on a number of factors including but not limited to tide level and volume released. In the event of a large spill, onsite personnel in consultation with the Port will determine if a suction dredge or similar needs to be mobilized to the spill site for recovery. Post spill (and clean up) water and sediment sampling would be conducted onsite and in adjacent areas to determine the potential effects of the spill and confirm that clean-up is completed consistent with the applicable provincial and federal guidelines. 3.2 Oil or Fuel Spill There is a potential for equipment working on site, and for the barge, to release oil, waste oil, hydraulic fluid, oily water/bilge, gasoline, diesel, solvents, antifreeze, grease, etc. to the receiving environment. The barge, dock, and soil receiving area will be equipped with spill kits to respond to this type of spill. In the event oils or fuel are spilled on the soil, the soils that are suspect are to be segregated and placed onto an impermeable surface and protected from the elements to prevent rain erosion or wind losses. This soil will be sampled consistent with the methods outlined in the Ministry of Environment s Technical Guidance on Contaminated Sites 1: Site Characterization and Confirmation Testing. On the basis of these results, soils will be classified and relocated or disposed of consistent with the requirements of their classification. 7 Project 12943 / March 2015
SENSITIVITY ANALYSIS While sensitivity analyses are generally included in contingency plans to provide information to aid the spill responders in planning and responding to the spill, the sensitivity analysis for this site is brief, primarily because of the nature of waste material received. Still, there are considerations in biological, social and economic aspects that may be affected by a spill that should be taken into account. 4.1 Biological Sensitivities Negative impact of a spill will come in the form of potential surface and ground water contamination. A spill within or off the site must be contained locally to minimize such impact. Soils spilled on land should be considered a "very low" spill risk because they are non-flowing materials, whereas soil spilled adjacent to, or in the water, is considered a higher risk. Oils, grease, fuels and solvents are considered a high spill risk. Federal and Provincial Transportation Regulations cover all safety aspects of transporting special wastes. There is also a response program in place to deal with a spill of waste materials. Westerra has established a transportation monitoring program of incoming waste delivery. This system will track incoming shipments so that any accidents can be quickly reported to ECC for their timely response. 4.2 Socio-Economic Sensitivities The socio-economic implications of a spill on or off the job site would depend on the nature of the spill. A soil spill on land, away from the marine environment, would have minor implications, whereas a soil spill into the marine environment or an oil spill may have greater consequences. 8 Project 12943 / March 2015
SPILL RESPONSE ORGANIZATION AND LOGISTICS The purpose of this section is to identify a response team structure that can cope effectively with spills that may accidentally occur at the work site. 5.1 Command System Response to larger spills will be handled by the ECC or their delegate, at their discretion. As the potential maximum size of spill is moderate - the size of a response team will be limited. Consequently, the command structure will be limited with few intermediates between the Incident Commander and the Response Crews. The designated on-site safety officer or the company safety officer will assume responsibility for overall direction of the response operation. The onsite safety officer will have authority to undertake any activity at his/her discretion. Depending on the situation of a spill, the ECC or delegate may assign command staff for functions of liaison, safety, and information. A liaison officer will liaise with assisting agencies. The safety officer will be responsible for ensuring the safety of all personnel and has authority to stop/prevent any unsafe actions. The safety officer may also advise on any issues of public safety. The information officer has the responsibility of assembling and distributing accurate and complete information on the event. The information officer is the point of contact for any outside group (media, government agency, public) that desires information on the event. 5.2 Communications Communication on or off site can be accomplished effectively in person. The on-site telephone lines serving the work area may be used for outside communications. Cellular phones are available at all times on the site. 9 Project 12943 / March 2015
SPILL REPORTING AND LIAISON The size of spill that will require reporting is dependent on the substance spilled and the corresponding specified amount under the Spill Reporting Regulation. As part of the Management Agreement, Westerra does not accept Hazardous Waste soils at the facility. 6.1 Spill Reporting Contact List This section is to emphasize local contacts for district and regional offices of response agencies that require reports of the spill event. The prime contacts are: Contact Phone Emergency Control Centre Duty Officer 1-800-663-3456 Westerra Enterprises Inc. Myles Hargrove 604-825-2010 Contact these agencies individually within a reasonable time (half a day) following a spill. 6.2 Spill Reporting The contents of the report under the Spill Reporting Regulation should include, to the extent practical: The reporting person s name and telephone number; The name and telephone number of the person who caused the spill; The location and time of the spill; The type and quantity of the substance spilled; The cause and effect of the spill; Details of action taken or proposed to comply with section 3 of the Spill Reporting Regulation 1 ; A description of the spill location and of the area surrounding the spill; The details of further action contemplated or required; The names of agencies on the scene; and, The names of other persons or agencies advised concerning the spill. A Spill Report Form is attached to this contingency plan in Appendix A. 1 Where a spill occurs, the person who immediately before the spill had possession, charge or control of the spilled substance shall take all reasonable and practical action, having due regard for the safety of the public and of himself or herself, to stop, contain and minimize the effects of the spill. 10 Project 12943 / March 2015
6.3 Public Information Immediately upon notification, the MoE Project Manager, or delegate, may attend the scene at their discretion. Initial statements about a spill will be confined to facts that will not be in dispute, such as: Identification of the location, name of project involved; Time of accident; Type of material spilled; Action being taken to control and clean up the spill; and The company's position concerning prevention of pollution, and actions planned to respond to a spill. Any information released can be used in legal action, so all response crew members are required to adhere to these public information guidelines. Under no circumstances should any information be released by the crew concerning: Speculation concerning liability for the spill or its legal consequences Speculation regarding the cause of the spill. An extended inquiry may be needed to determine the actual cause. Legal liability could be affected by what is said Estimate of damage expressed in dollars Estimates of damage to ecology Promises that property, ecology or anything else will be restored back to normal Requests for, or implications of, need for volunteers to help Opinions concerning the appropriateness of government response to the spill An approved facts sheet may be prepared and distributed to police and response crews to relay to interested media and onlookers, if approached. 11 Project 12943 / March 2015
CONTAINMENT AND CONTROL 7.1 Spill Kits Spill kits will be placed on the barge, the dock, and various locations on site, including at the site scale house. The kit is designed to contain and clean-up minor spills that may occur, and provide initial response to larger spills before the Fire Department or agency response teams arrive. Spill kits must be maintained in a functional condition with sufficient sorbent materials, gloves and portable disposable containers for used sorbent material. The locations of large site spill kits shall be clearly signed and the kits themselves must be signed to identify the spill capacity for which the kits are intended. Figure 1 shows the locations of the spill kits. Spill kits must be checked on a regular basis to ensure all contents of the kits are replenished. Each spill response kit contains: 50 absorbent pads 4 booms 1 bag of granular absorbent Shovels Heavy duty disposal bags Roll of heavy duty plastic sheeting 4 pairs rubber lined work gloves Sets protective clothing waterproof overalls, hard hats, gloves, gum boots, goggles, respirators Copy of Emergency Response Plan with notification procedures and contact telephone numbers, and spill report forms Site plan Up to 80 sandbags (empty) Small tool kit In addition, emergency kits at the site scale house will contain: 6 volt flashlights Clipboard and writing pad 100 ft. 1/4" rope Medical first aid kit Eye wash station 20-litre buckets 12 Project 12943 / March 2015
Fire extinguisher foam and dry ladder 100 fire hose (connectable) Trash pump Water storage tank Hammer Axe The spill kits will be restocked after use. Several items of equipment that are used during the course of regular project operations are maintained on site and suitable for emergency response. These are discussed below. Any additional response equipment needed for responding to major spills must be brought on site by the response agencies such as the Fire Department or ECC crews. 7.2 Equipment Capabilities and Limitations Water storage on site is limited to the water storage tank. The water should be adequate in most circumstances to fight fires. Water will be drawn from the on-site storage tank as required in the event of an emergency. There will be one portable auxiliary water pump (trash pump) located on the site that will be mobilized in the event of fire. Water will be drawn directly from the storage tank and will be equipped with 100 ft of standard fire hose. 7.3 Equipment Storage and Maintenance Westerra maintains a scale house on site for storage of response equipment and other unused equipment. Spill kits are located in strategic locations throughout the site (see Figure 1). The scale house will be locked whenever Westerra personnel are not on site. Keys can be obtained through Westerra personnel listed in the notification section of this contingency plan (Section 1.4.3). If required, a set of keys can be left with the local Fire Department. 7.4 Safety of the Clean-up Crew Standard workplace procedures as outlined in the site Health and Safety Plan continue to be in effect for response workers. Some of the key requirements are discussed below. Fire hazard should be assessed prior to assigning response tasks to personnel. The organic gas levels on site shall be tested at the time of a spill with an organic gas monitor operated by the facility/project safety officer. If levels are excessive, workers shall wear respirators. All response personnel on site shall be equipped with personal respirators. 13 Project 12943 / March 2015
Full protective clothing shall be worn by response workers. On leaving the site, the outer clothing shall be considered contaminated and undergo decontamination procedures (shower and washings). 14 Project 12943 / March 2015
ASSESSMENT AND SURVEILLANCE 8.1 Monitoring Procedures The site will be considered clean when all soil, surface water and groundwater contamination is removed from the site. A lack of visual or olfactory indications of contamination does not necessarily mean that all contamination has been removed. A qualified environmental consultant will have to be retained to collect soil samples to be tested for contaminants of concern. The Project Manager will arrange to have a consultant on-site during the clean-up program. 8.2 Documentation Procedures In addition to the reporting procedures described in Section 1.3, a full report of the spill event will be submitted to regulatory agencies and companies affiliated with the project listed in Section 1.4.3, as required. This report will summarize the details outlined in the series of spill report forms completed during the spill. A post-mortem analysis will be conducted on the spill response, identifying any shortfalls and recommending improvements. 15 Project 12943 / March 2015
TRAINING 9.1 Objectives The training objectives are to prepare all field crew personnel in response procedures. The procedures that need to be reviewed include most topics described in this contingency plan: Notification procedures Health and Safety Procedures Hazard Analysis Sensitivity Analysis Response Command System Reporting Requirements Equipment Inventories and Operation Spill Assessment and Monitoring Procedures Financial Procedures 9.2 Training of Personnel Training required of the field crew includes standard safety and health procedures. First aid and CPR courses are applicable to this project and must be taken. Response training involves working through practice scenarios of spills on the site. The procedures identified in the objectives above will be described using this plan as reference to the goals and requirements of a response. The main thrust of the training sessions will concentrate on administrative and reporting requirements of the crew. To better facilitate employees, all training will occur on site and will encompass the full range of in-classroom and hands-on training. Employees will learn correct emergency reporting procedures, as well as understand and implement field response procedures. A good understanding is required of all working and mechanical components in and around the site. As part of the total training package, employees will be made familiar with the overall facility operation. The total length of time required for training is estimated at 1 day and will offer employees a good understanding of the emergency response procedures and reporting duties. All training will be held on site and will be part of the responsibility of senior Westerra personnel. The facility will work closely with the local fire department in setting up procedure and training and to improve overall firefighting capabilities of the community. 16 Project 12943 / March 2015
SPILL CONTROL AND CLEAN-UP PROCEDURES The following procedures should be followed as soon as possible by site personnel: 1. Remove personnel from spill site; remain upwind. 2. Contact emergency response team. 3. Put on protective clothing (respirator, coveralls, boots, gloves, safety glasses, hard hat). 4. Prevent liquids from entering water courses, drains, streams, etc. by diking or by digging ditches. 5. Absorb any liquids with absorbents and/or soils. 6. Cover spill area with plastic if appropriate. 7. Take other actions as directed by Westerra s emergency coordinator. 8. Delineate spill area. 9. After removing contaminated clothing, place in plastic bag and seal. 10. Wait for Westerra s emergency response team to arrive, and comply with the police and fire department s instructions. 10.1 Restoration of Spill Site Corrective measures include, but are not limited to the following: 1. Assess quantity spilled. 2. Delineate the area of contamination through sampling and analytical testing. 3. Evaluate available clean-up technologies (skimmers, vacuum trucks, booms, absorbent pads, etc.). 4. Assess impact of clean-up on environment. 5. Continuously evaluate worker safety. 6. Evaluate treatment and/or disposal options. 17 Project 12943 / March 2015
FIGURE
APPENDIX A SPILL REPORT AND NOTIFICATION FORM